NIH Data Management and Sharing Policy FAQ

The University’s Research Data Ownership Policy states that Harvard University asserts ownership over research data for all projects conducted at the University, under the auspices of the University, or with University resources. This enables the University to respond to inquiries from funders and third parties, as well as appropriately protect the data, data subjects, and researchers. Principal Investigators (PIs) and other researchers are stewards and custodians of research data. Therefore, the PI’s responsibilities with respect to research data include: 

• Ensuring proper management and retention of research data in accordance with the Guidance on Retention and Records of Research Records and Data 

• Establishing and maintaining appropriate procedures for the protection of research data 

• Ensuring compliance with program requirements 

• Maintaining confidentiality of research data 

• Maintaining appropriate data use agreements for the sharing of research data 

• Complying with applicable federal, state, and local laws and regulations 

Permanent retention or archiving refers to the ongoing migration of electronic formats and storage costs, as well as care, maintenance, and access services for the records in perpetuity. The Records Management Services, a department of the Harvard University Archives, provides guidance to University staff, faculty, and administrators on how to understand their responsibilities for stewarding and managing their records.